Narrative Opinion Summary
In this case, the appellant challenges the imposition of consecutive sentences for first degree assault and first degree murder, arguing violations of Blakely v. Washington principles. The appellant contends that his juvenile adjudications should not contribute to his offender score and that consecutive sentences require jury findings under Blakely and Apprendi v. New Jersey. The trial court sentenced the appellant consecutively, citing RCW 9.94A.589(3), which allows such sentencing if explicitly ordered by the court, without further factual findings. The Court of Appeals affirmed this decision, referencing State v. Cubias to support the non-application of Blakely to consecutive sentences. The appellant also argued that the Washington Constitution provides greater jury trial rights, but the court found this argument irrelevant due to the statute's clear grant of discretion. Furthermore, the inclusion of juvenile adjudications in the offender score was upheld, as they were deemed constitutionally compliant. Ultimately, the appellate court affirmed the trial court's sentencing decision, maintaining the validity of consecutive sentencing under the statutory framework provided by RCW 9.94A.589(3).
Legal Issues Addressed
Application of Blakely v. Washington to Consecutive Sentencessubscribe to see similar legal issues
Application: The principles of Blakely do not require jury findings for consecutive sentencing decisions.
Reasoning: The State argues that, per State v. Cubias, the principles of Blakely and Apprendi do not apply to consecutive sentences and that RCW 9.94A.589(3) allows the court discretion to impose such sentences without requiring further factual findings.
Consecutive Sentencing under RCW 9.94A.589(3)subscribe to see similar legal issues
Application: The trial court has discretion to impose consecutive sentences without additional factual findings if explicitly ordered.
Reasoning: The trial court imposed a consecutive sentence on Champion under RCW 9.94A.589(3), which allows consecutive sentencing if expressly ordered by the court.
Inclusion of Juvenile Adjudications in Offender Scoresubscribe to see similar legal issues
Application: Juvenile adjudications can be included in offender scores without violating Sixth Amendment rights if due process was observed.
Reasoning: The State contends that including juvenile adjudications does not violate Blakely, asserting that these adjudications meet constitutional safeguards and that Champion waived his rights by signing a stipulation regarding his record.
Washington Constitution's Jury Trial Rightssubscribe to see similar legal issues
Application: The argument that the Washington Constitution offers greater jury trial rights for sentencing was deemed irrelevant under the statute granting sentencing discretion.
Reasoning: Champion asserts that the Washington Constitution, per State v. Gunwall, offers greater jury trial rights than the federal constitution... However, the trial court did not rely on this finding, as the statute grants it total discretion, rendering Champion's Gunwall argument irrelevant.